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Okay, got through the proposed rules, it's interesting.
The biggest caveat, of course, if they neither the proposed regs, nor UIGEA, or any other law, truly explicitly what is a defined internet gambling transaction, and what is not. Anyway.
- Ewallet, credit/debit card networks, and money transfer businesses would be assumed to have perfect knowledge of each restricted transaction, and block them.
- Checks are generally exempt, exempt the bank receiving the deposit (has a relationship with the gambling business) is expected to prevent such checks from being presented.
- ACH is generally exempt, excempt the bank originating the ACH debit is also expected to prevent such transactions from being originated.
- Wires are generally exempt, exempt for the bank receiving the funds.
However, since virtually all net gambling is of an cross-border, the regs are proposed to apply to the first bank in the US food chain, the one that corresponds with the foreign bank or payment processor. This is where the regs still get pretty squishy. The suggested would be a contractual agreement with the foreign payment processor that they will not originate restricted transactions, thus "exporting" the restriction to the foreign institution. It becomes a know your customer's-customer's-customer situation.
Also, the regs bring up the idea of maintaining a federal blacklist, but they recommend against it.
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